According to a weekly Defense Nuclear Facilities Safety Board memorandum, lab director Charlie McMillan provided a final response to a September 2011 NNSA Site Office letter regarding criticality safety infractions last month.

Charlie McMillan

In his response, McMillan provided the results of laboratory causal analysis of four key identified problem areas:
• Why are Technical Safety Requirement (TSR) violations occurring?
• Why are criticality safety infractions occurring?
• Why are issues and deficient conditions, which should be discovered by LANS personnel, being found by NNSA Facility Representatives and other outside groups?
• Why do personnel have difficulty executing procedures and work packages?
McMillan unveiled the LANL analysis, identifying deficiencies and causal factors into five judgments of need related to:
• Strengthening management emphasis on Nuclear Safety Culture, self-discovery, reporting free from fear of retaliation, and continuous improvement;
• Improving clarity and understanding of roles, responsibilities, authority, and accountability;
• Enhancing issues management with corrective actions directed at causes rather than symptoms to support continuous improvement;
• Elevating management attention on the training and qualification program;
• Improving effectiveness of technical procedures as tools for workers.

In the response, the director also announced the establishment of a Senior Executive Committee on Nuclear Safety that will be chaired by the associate director for Nuclear and High Hazard Operations. This committee will be responsible for addressing the five identified judgments of need and directing future improvements to nuclear safety and operations.

The September 2011 report from DNFSB said a criticality safety infraction was declared at the Plutonium facility.

According to the report, “In order to take pictures of several cast plutonium items in a glove box, a plutonium worker removed the items from two separate slip lid containers in two different mass locations. The worker then collocated the items to take a picture. This resulted in a total mass that exceeded the criticality safety limit. An angle iron spacing delimiter that is a criticality safety engineered feature was also moved from its required location and used to prop up the items for the photographs.

“A second plutonium worker entered the area and recognized the over-mass condition. The first worker then moved the items back to their original location. This action is not consistent with criticality safety expectations and procedures, which require workers to back off and contact criticality safety personnel.

“Workers in the lab room were notified of the issue and the room was evacuated and facility management was notified. Subsequent evaluation by criticality safety personnel concluded that the current position of the items (i.e. after the worker returned the items to the separate locations inside slip lid containers) was safe and consistent with criticality safety requirements.”

A meeting was scheduled a day later and Plutonium Science and Manufacturing Directorate management conducted an all-hands briefing followed by breakout sessions at the group level to discuss the briefing and lessons learned.

The briefing focused on conduct of operations, criticality safety requirements, work authorization and lessons learned from this and other criticality safety issues. Management will authorize individual group activities to resume after this training is complete. All Plutonium Facility personnel were required to complete this training prior to being authorized to perform work.

In the same memorandum, LANL also issued a corrective action plan to the site office for recovery from recent criticality safety issues identified at TA-35, including the discovery of three unaccounted for fuel rods in May and identification of fuel rods with active lengths that may exceed the length identified in the criticality safety evaluation in June. LANL’s plan includes compensatory actions and a path forward to ensure proper accounting and disposition of the fuel rods; however, it did not incorporate actions required to respond to a recent site office memo on the TA-35 criticality safety issues.

The LASO memo requests that LANL evaluate the following three options:
• De-inventory sufficient fuel rods to preclude criticality concerns;
• Upgrade the hazard categorization of certain facilities in TA-35 to hazard category two; or
• Improve the “nature of the process” arguments that allow these TA-35 facilities to be radiological (i.e. less than hazard category three) facilities per DOE Standard 1027.

The memo states, “The site office did not take action on the LANL corrective action plan and instead requested that LANL incorporate the actions and path forward into a recovery plan that adequately addresses all LASO requested actions. Programmatic operations associated with these fuel rods remain suspended pending LANL development and site office approval of a recovery plan.”